WHA Comments on CMS Proposed IPPS Rule

Supports “96-hour” rule language

June 16, 2017

On June 13, the Wisconsin Hospital Association (WHA) submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed FY 2018 Inpatient Prospective Payment System (IPPS) rule for acute care and long-term care hospitals (LTCH). 

WHA’s comments highlighted a variety of issues in the proposed rule, including expressing concerns with CMS’s proposal on posting of accrediting organization survey findings as well as concerns with the accuracy and consistency of “Worksheet S-10” data among others. WHA also provided comments specific to long-term care hospitals, including provisions related to the “25% rule,” outlier payments, co-located LTCHs and the quality reporting program. 

WHA also commented on language included by CMS in the proposed rule related to the 96-hour certification for critical access hospitals (CAHs). CMS indicated in the proposed rule that, based on feedback from stakeholders and to reduce regulatory burden, it was directing Quality Improvement Organizations, Medicare Administrative Contractors, the Supplemental Medical Review Contractor and Recovery Audit Contractors (RACs) to make the CAH 96-hour certification requirement a low priority for medical record reviews conducted on or after October 1, 2017. Further, CMS indicated it would not authorize any medical record reviews by the RACs related to this issue. 

WHA has long raised the need to address the 96-hour certification requirement and appreciates CMS’s directive to its contractors. However, WHA continues to advocate to Congress that a legislative fix is needed to permanently remove the 96-hour physician certification requirement as a condition of payment for CAHs. 

Finally, WHA also provided comments, as requested by CMS, related to reducing regulatory burdens. Those comments highlighted audit and quality reporting burdens among others. WHA will respond in a separate letter to CMS’s request for comments on regulatory burdens stemming from the Affordable Care Act. 

Read WHA’s IPPS LTCH comment letter at www.wha.org/pdf/2018WHAIPPS_Proposed_Rule6-13.pdf.

This story originally appeared in the June 16, 2017 edition of WHA Newsletter